After Searching High and Low, There Is an Opportunity in the Middle

Later this week, at its August meeting, the FCC will consider a Notice of Inquiry exploring whether and how mid-band spectrum (between 3.7 GHz and 24 GHz) can be made available for wireless broadband. Having already shown a commitment to freeing up essential low- and high-band spectrum for commercial use, Mobile Future enthusiastically welcomes the Commission’s continued leadership to address our nation’s critical spectrum needs.

Consumers, businesses, and communities of all kinds consistently demonstrate a growing thirst for data-intensive services and applications that are already tugging hard on existing 4G networks and Wi-Fi connections. This demand will increase exponentially as next-generation 5G services, the Internet of Things, and “smart communities” proliferate across the country. The opportunities are endless – for education, healthcare, job creation, and virtually every aspect of our society – but the current supply of spectrum to meet this demand is not.

According to two studies, by 2022, the average home could have as many as 500 connected devices, and 25 percent of North American mobile subscriptions will be 5G connections. Cisco predicts that over the next five years in the U.S., mobile data traffic will reach 6.1 exabytes per month, up from 1.3 exabytes per month in 2016, and mobile traffic per mobile-connected end-user device will reach 13,096 megabytes per month, up from 3,510 megabytes per month in 2016. Absent new spectrum for mobile broadband, wireless networks will struggle to keep pace with this skyrocketing consumption.

The demand will put a premium on carriers’ ability to offload traffic to Wi-Fi networks which are also increasingly congested. According to Cisco projections, 70 percent of U.S. mobile data traffic and 50 percent of all IP traffic (fixed and mobile) will be offloaded onto Wi-Fi connections by 2021. Yet, earlier this year a study detailed the growing congestion in the unlicensed airwaves used for Wi-Fi, finding that demand will exceed the capacity of spectrum currently available in the 5 GHz band by 2020 and that between 500 MHz and 1 GHz of additional spectrum may be needed to support expected growth in Wi-Fi by 2020.

These dual needs – more licensed spectrum for mobile broadband and more unlicensed spectrum for Wi-Fi – are what makes exploring mid-band spectrum so promising, particularly spectrum at 3.7-4.2 GHz and 6 GHz. Commissioner O’Rielly correctly stated that “[w]hen presented with a viable proposal that would free spectrum for licensed and unlicensed purposes while protecting or accommodating incumbent licensees, the Commission should grab it with both hands and rejoice” and “that exact scenario presents itself in the 3.7 to 4.2 GHz and 6 GHz bands.”

Congress has also shown foresight and leadership in looking for mid-band spectrum opportunities. Chairman Thune’s Mobile NOW Act would ensure that large swaths of spectrum, including spectrum in the mid-band range, are made available for commercial use by 2020, and he has urged the FCC to “explore new allocations in the mid-band frequencies, perhaps including the 3.7 GHz and 6 GHz bands.” Other Members of Congress, including Communications Subcommittee Ranking Member Doyle are also exploring legislative options to make mid-band spectrum available for commercial use by the end of the decade. This effort has support from both sides of the aisle and offers a welcome opportunity for bipartisan cooperation.

Finally, it is critical that we act now to ensure America’s continued leadership in the wireless broadband sector. Other countries in Europe and Asia are pushing hard to allocate hundreds of megahertz of mid-band spectrum for licensed and unlicensed use. The U.S. has shown global leadership in the recently concluded 600 MHz incentive auction and earlier efforts to liberate low-band spectrum for commercial use. The Commission has acted with speed and precision in the Spectrum Frontiers proceeding for high-band spectrum. It is critical that we do the same for mid-band spectrum.

Spectrum in the 3.7-4.2 GHz and 6 GHz bands offers a middle-ground opportunity between high- and low-band spectrum, with more favorable propagation characteristics than the high-band spectrum above 24 GHz. These frequencies also offer higher capacity than low-band spectrum. Thanks to the FCC, stakeholders are poised to begin a conversation about how spectrum can be put to its highest and best use.

As with any new proposals, challenges lie ahead. The FCC’s vote on Thursday will forge new policy innovations that will shape technological innovation. It will be a great day for our mobile future.